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This provision authorizes teachers in Duolingo for Schools to access student names, email addresses, learning progress data, and to log in as the student to manage their account. Students can remove teacher access by leaving the classroom in app Settings.
This analysis describes what Duolingo's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes a delegated account access model in which teachers can authenticate as students and access account management functions, which creates data access and identity management considerations under FERPA and applicable state student privacy statutes where school-affiliated accounts involve minors.
The updated policy removes explicit language stating that Android users and website users are not subject to audio collection for product improvement purposes. Previously, the policy authorized audio collection only from iOS users, with an explicit carve-out for Android and web users. The revised language now states that all users may choose not to share audio within app Settings, suggesting audio collection may now occur across all platforms unless the opt-out mechanism is used. The practical operational effect of this change depends on whether Duolingo implements audio collection on Android and web platforms, which the policy change does not explicitly confirm. You can decline audio sharing for product improvement by adjusting the setting within the app.
View change record →Under this provision, teachers in a joined Duolingo for Schools classroom may access the student's name, email address, and learning activity data, and may log in as the student to manage account settings. Students and parents can remove teacher access by leaving the classroom through the Duolingo for Schools section in app Settings.
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"If you accept an invitation to join a classroom, teachers can see your name and email address, can reset your password, can send you login links, and can log in as you to help manage your account. Be sure to only join classrooms of teachers you know. Teachers can email you learning assignments, and can see your learning progress, such as what lessons you studied, how long you spent on a lesson and how many XP you earned. To withdraw consent and remove all teacher control and their access to your data you can leave a classroom at any time by accessing the Duolingo for Schools section within the app Settings.Excerpt from Duolingo's Privacy Policy
1) REGULATORY LANDSCAPE: This provision implicates FERPA, which governs access to student education records and requires consent for disclosure to parties other than school officials with legitimate educational interest. Applicable state student privacy statutes (including California's Student Online Personal Information Protection Act and similar state laws) may impose additional restrictions on the scope of data access granted to teachers. COPPA is relevant where participating students are under 13. 2) GOVERNANCE EXPOSURE: High. The authorization for teachers to log in as students constitutes a form of credential sharing and delegated account access that may exceed the scope of standard educational platform data access models. Institutions deploying Duolingo for Schools should assess whether this access model satisfies their own data governance policies and FERPA's legitimate educational interest standard. 3) JURISDICTION FLAGS: All U.S. school-affiliated deployments implicate FERPA. California, New York, and other states with enacted student privacy laws create additional compliance obligations. EU and UK school deployments may face GDPR Article 9 restrictions if student data includes special category information, and GDPR Article 28 data processing agreement requirements apply to the teacher-as-processor relationship. 4) CONTRACT AND VENDOR IMPLICATIONS: Institutions procuring Duolingo for Schools should review whether Duolingo's data processing agreements satisfy FERPA's written agreement requirements for school officials and service providers. The teacher login-as-student capability should be assessed against institutional acceptable-use policies and IT security standards regarding shared credential access. 5) COMPLIANCE CONSIDERATIONS: Legal and compliance teams at educational institutions should evaluate whether the Duolingo for Schools access model requires a FERPA-compliant data processing agreement prior to deployment. Consent mechanisms for student participation should be reviewed, particularly where students are minors. The policy's opt-out mechanism (leaving the classroom) should be verified as immediately effective in revoking teacher access.
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This provision establishes a delegated account access model in which teachers can authenticate as students and access account management functions, which creates data access and identity management considerations under FERPA and applicable state student privacy statutes where school-affiliated accounts involve minors.
Under this provision, teachers in a joined Duolingo for Schools classroom may access the student's name, email address, and learning activity data, and may log in as the student to manage account settings. Students and parents can remove teacher access by leaving the classroom through the Duolingo for Schools section in app Settings.
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